Nexus Requirements for Taxation of Non-residents' Business Income: A Normative Evaluation in the Context of the Global Economy

Type Book

Author(s)

Stjepan Gadzo

Series

IBFD Doctoral Series

Date of publication

June 2018

DOI https://doi.org/10.59403/emy4w5

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Nexus Requirements for Taxation of Non-Residents’ Business Income

The book aims to find a global dimension of the non-discrimination principle in tax law through the analysis of issues with theoretical and practical importance.

Why this book?

The principle of non-discrimination is an evergreen of international tax law. While the principle’s core concept remains stable, its importance in tax matters keeps growing. As its implications, regional dimensions and topical applications very frequently change around the world, constant monitoring and updating is essential to seize its current essence.

Non-Discrimination in Tax Treaties: Selected Issues from a Global Perspective aims to find a global dimension of the non-discrimination principle in tax law through the analysis of issues with theoretical and practical importance. The editors have selected the following issues, which nine leading European and international tax law experts address in the framework of related topical studies:

Nationality non-discrimination and article 24 of the OECD Model Tax Convention
Non-discrimination on the basis of nationality in international investment agreements from a Latin American tax perspective
Interest deduction limitations and when to apply articles 9 and 24(4) of the OECD Model Tax Convention
Revisiting the application of the capital ownership non-discrimination provision in tax treaties
Non-discrimination in tax treaties and article 24(4) and (5) of the OECD Model Tax Convention: a Russian approach to tax treaty interpretation in connection with domestic thin capitalization rules
Non-discrimination under WTO law and article 24 of the OECD Model: how policy considerations influence comparability and whether less favourable treatment of tax havens and hybrid mismatch arrangements constitutes unjustified discrimination
Can the European Union learn from the OECD Model Tax Convention and vice versa?
Non-discrimination à la Cour: the ECJ’s (lack of) comparability analysis in direct tax cases
Discriminatory taxation and the European Convention on Human Rights

With its in-depth analysis of these topical issues, this book provides essential information for practitioners, scholars and others with an interest in international tax matters.

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Sample excerpt, including table of contents

Review

Reviewed by: Christiana HJI Panayi Professor in Tax Law, Queen Mary University of London, Centre for Commercial Law Studies.

"Overall, this book provides an impressive analysis of some of the important issues relating to jurisdiction to tax a non-resident’s business income and especially the PE concept. The author’s proposal is very well argued and quite convincing. Whilst it appears to precede the European Commission’s 8 and the OECD’s 9 2018 proposals on the taxation of digital economy, it provides an excellent benchmark for further research and a solid alternative if the existing proposals do not gain consensus."